Connie McAllister v. DeSoto County, Mississippi, e
470 F. App'x 313
5th Cir.2012Background
- McAllister sued Coleman, Davis, and Desoto County under §1983 for unlawful arrest and MTCA gross negligence.
- Officers relied on Williams transactions and Eagle System to identify McAllister as the drug dealer Connie Mac.
- Indictments were issued; McAllister was arrested, jailed briefly, and later released when misidentification was revealed.
- Connie Faye McAllister, the actual dealer, was subsequently arrested for the cocaine counts.
- District court granted summary judgment: qualified immunity for officers; MTCA discretionary-function immunity for County.
- On appeal, court affirmed, reviewing de novo and applying Fourth Amendment objective reasonableness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did McAllister have a Fourth Amendment right violated? | McAllister: no probable cause; officers acted unreasonably. | Officers reasonably believed McAllister was Connie Mac; probable cause via mistaken identity. | No Fourth Amendment violation; qualified immunity applies. |
| Are Coleman and Davis entitled to qualified immunity? | Officers acted with unreasonable, incompetent conduct. | Arrests were reasonable under probable cause with good faith mistake. | Yes, officers entitled to qualified immunity. |
| Does the independent intermediary doctrine defeat liability? | Independent intermediary doctrine should not shield officers. | Doctrine applies because grand jury issued indictments and no falsification. | Not reached as qualified immunity affirmed. |
| Was the County immune under MTCA discretionary-function exemption? | County should face liability for gross negligence. | Discretionary-function exemption immunizes County. | County immune under discretionary-function exemption; MTCA supports summary judgment. |
Key Cases Cited
- Hill v. California, 401 U.S. 797 (1971) (probable-cause reasonable mistake valid arrest)
- Haggerty v. Texas S. Univ., 391 F.3d 653 (5th Cir. 2004) (probable cause standard for Fourth Amendment arrest)
- Blackwell v. Barton, 34 F.3d 298 (5th Cir. 1994) (good-faith belief permits arrest despite mistaken identity)
- Gerstein v. Pugh, 420 U.S. 103 (1975) (valid indictment influences probable-cause assessment post-indictment)
- Pearson v. Callahan, 555 U.S. 223 (2009) (two-prong qualified-immunity analysis; courts may choose order)
- Turner v. Baylor Richardson Med. Ctr., 476 F.3d 337 (5th Cir. 2007) (summary-judgment standard and qualified immunity framework)
- Messerschmidt v. Millender, 132 S. Ct. 1235 (2012) (clarifies reasonable-suspicion and discretionary decisions in searches/arrests)